PRA Supporting Statement B (14-090-AUD-FEMA)

SUPPORTING STATEMENT FOR

DHS OIG Audit of FEMA’s Assistance to Firefighters Grant Program

OMB Control No.: 1601-NEW

COLLECTION INSTRUMENT(S):

1. AFG Grant Collection Instrument

2. SAFER Hiring Grant Collection Instrument

3. SAFER Recruitment and Retention Grant Collection Instrument

B. Collection of Information Employment Statistical Methods

The agency should be prepared to justify its decision not to use statistical methods in any case where such methods might reduce burden or improve accuracy of results. When Item 17 on the Form OMB 83-I is checked "Yes", the following documentation should be included in the Supporting Statement to the extent that it applies to the methods proposed:

1. Describe (including a numerical estimate) the potential respondent universe and any sampling or other respondent selection methods to be used. Data on the number of entities (e.g., establishments, State and local government units, households, or persons) in the universe covered by the collection and in the corresponding sample are to be provided in tabular form for the universe as a whole and for each of the strata in the proposed sample. Indicate expected response rates for the collection as a whole. If the collection had been conducted previously, include the actual response rate achieved during the last collection.

The Assistance to Firefighters Grant program is administered by the Federal Emergency Management Administration (FEMA) and consists of grants awarded directly to fire departments to enhance their ability to protect the public and fire service personnel from fire and related hazards.

The Assistance to Firefighters Grant program has three grant sub-programs: 1) Assistance to Firefighter Grants (AFG) 2) Staffing for Adequate Fire and Emergency Response Grants (SAFER) and 3) Fire Prevention & Safety Grants (FP&S). The scope of our collection will be limited to AFG and SAFER grant award recipients for grant fiscal years 2010 to 2012.

Volunteer, combination and career fire departments and statewide or local volunteer firefighter interest groups are eligible to apply for SAFER funding.

Fire departments and non-affiliated Emergency Management Service organizations are eligible to apply for AFG funding. Organizations applying for AFG funding must operate in one of the 50 States, the District of Columbia, the Commonwealth of the Northern Mariana Islands, Virgin Islands, Guam, American Samoa, or Puerto Rico.

The table below presents the total number of grant awards in the scope of the audit as well as the sample size based on statistical sampling methods.

	Total number of grant award recipients from grant fiscal years 2010 to 2012 1	Sample size 2
AFG	7153	365
SAFER	1071	283

Per FEMA grant guidance and grant award letters, grant recipients are required to conform to either 44 CFR Part 13, Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Government or 2 CFR Part 215, Uniform Administrative Requirements for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations.

Both regulations stipulate that records must be retained for three years after submission of the final expenditure report for the grant; therefore, the OIG expects a 100% response rate from our sample selection.

2. Describe the procedures for the collection of information including:

• Statistical methodology for stratification and sample selection,

• Estimation procedure,

• Degree of accuracy needed for the purpose described in the justification,

• Unusual problems requiring specialized sampling procedures, and

• Any use of periodic (less frequently than annual) data collection cycles to reduce burden.

We randomly selected 365 AFG grant award recipients and 283 SAFER grant award recipients. We will initially request that FEMA contact the randomly selected grantees via email to describe our audit objective and request for cooperation. The DHS OIG will follow-up with the grantees via email to request completion of a questionnaire (see attachments 5a through 5d) and submission of supporting documentation.

To reduce the burden on grantees, the OIG will only request supporting documentation that is required to be retained by the grantee but not regularly submitted to FEMA during the grant life cycle. Supporting documentation are items such as invoices for items/services purchased, written procurement policies, and proof of payment to vendors for items/services purchased. The data collection for this audit will be a one-time request.

3. Describe methods to maximize response rates and to deal with issues of non-response. The accuracy and reliability of information collected must be shown to be adequate for intended uses. For collections based on sampling, a special justification must be provided for any collection that will not yield "reliable" data that can be generalized to the universe studied.

All of the grantees are known to FEMA in its Assistance to Firefighter Grant Program database. Grantee contact information is contained in this database.

The DHS OIG will monitor responses continually and will contact non-respondents periodically with individualized reminders to maximize response rates. A deadline will be established once the request is approved and will not be earlier than 30 days from the request for data. Any non-responsive grantees after that date will be included in the audit report as a finding.

4. Describe any tests of procedures or methods to be undertaken. Testing is encouraged as an effective means of refining collections of information to minimize burden and improve utility. Tests must be approved if they call for answers to identical questions from 10 or more respondents. A proposed test or set of tests may be submitted for approval separately or in combination with the main collection of information.

The audit team conducted survey work prior to determining the methodology for this collection. Survey work consisted of site visits to a variety of fire departments and types of grants. The collection requirements were refined to exclude information FEMA would have in its grants database.

5. Provide the name and telephone number of individuals consulted on statistical aspects of the design and the name of the agency unit, contractor(s), grantee(s), or other person(s) who will actually collect and/or analyze the information for the agency.

Individual consulted on statistical aspects of the design:

Mohammad (Faizul) Islam

DHS - OIG Statistician

202-254-4203

1 Grant award recipient information obtained from FEMA.

2 Sample size calculated with a 95% confidence interval, 5% sampling error, and 50% population proportion.

3